PRIVACY POLICY

At Enuma, Inc. (“we,” “our,” or “us”) we are committed to safeguarding the on-line and information privacy of the users of our websites and applications. This privacy policy describes the information collected by us through our apps and websites and how the information is used and/or disclosed. We believe that providing this information empowers you to feel secure about the website and app choices you make. We adhere to the regulations under the Children’s Online Privacy Protection Act (COPPA), Federal Educational Rights and Privacy Act (FERPA), California’s Student Online Personal Information Protection Act (SOPIPA) and state breach laws, and are a proud member of ACT \ The App Association’s What’s Inside program.

Our websites provide information to parents, educators and other interested community members about our company and products-- assistive and play-based learning applications to empower children with special needs to be independent learners. The website is not for the use of children under the age of 13. It contains links to Facebook, Twitter, YouTube and Pinterest.

NO THIRD-PARTY ADVERTISING

Todo apps are designed to help children experience success in their learning. They do not have third-party advertisements so that young learners stay focused on their learning experience. Any in-app upgrades or purchases, links to our apps in the App Store, links to our websites or social media pages can only be accessed through a parental gate. These apps do not enable children to make their personal information publicly available.

Kid In Story apps are created for parents and educators to use social stories to support children’s learning, social modeling and early literacy.

COLLECTION AND USE OF INFORMATION

From Our Apps: Todo Math, Todo Telling Time Todo Matrix, Kid In Story

We do not collect personally identifiable information, such as first and last name, address, or email, when you first download our apps. We only collect persistent identifiers from your device for internal purpose to improve our app design and performance. For example, we collect information on app crashes, usage time, games played and problems missed. We do this ourselves and through third party providers: We do not track any more information than is necessary to improve the quality of our apps and services. Information collected by third party providers is used solely by our and the third party providers’ internal purposes and not shared with anyone else. They may aggregate information across their developers in a non-personally identifiable way.

With some of our apps, you create "Profile Names" for each player, which allows you to set up multiple profiles on a single device. These apps will track each child's play data separately to provide personalized activities and levels for each profile. Profile names remain on your device only and are not collected by us until you sign up for a parent or school account. Only parents or educators may sign up for a parent or school account by entering through a parental gate. When you sign up for a parent account, we collect and verify the parent's email address. With such an account, we provide to you additional services, such as multiple profiles, your child's progress reports and additional resources. The Profile Names, along with birth month and year, will be collected in order to personalize your reports. No other personal information is collected. We do not share, disclose or sell the information we collect with any third parties besides sharing progress reports with you.

School Services and Teacher Dashboard

For school accounts and school-based services, a school administrator or educator signs up for a school account, whereupon we collect the administrator's or educator's name, email address, school name and city. Todo Math for the Classroom includes a web-based Teacher Dashboard to facilitate student account management within a classroom or student group. Limited information is collected from teachers for use within the dashboard. To set up the dashboard, an educator sets up student nicknames or first names and accessibility options. The Todo Math app collects student play data thru persistent identifiers. This allows us to provide progress reports on problems solved and missions completed, mapped to Common Core Mathematics Standards. All information collected from our apps and services are for the use of Enuma’s internal purposes to provide and improve services and for educational purpose of the students, schools and parents only.

We do not collect more information than is necessary for the educational purpose of our services. Nor do we use this information for any other commercial purpose. We do not use the information for creating profiles on students or for advertising. Furthermore, we do not share, disclose or sell the information we collect with any third parties except where:

we use third party service providers, such as Amazon Web Services and Flurry’s Restricted Version in the collection and storage of our data. Such third party providers use the information only for the services we contract them to do; and

we share anonymous and de-identified data with third parties to research how to improve the educational effectiveness of our products.

As permitted by FTC’s guidelines of COPPA, we rely on teachers and schools to obtain parental consents if and when they are necessary. Schools and parents may ask for the following by contacting us at support@enuma.com. Upon request by schools, we delete student data. This student data consists of nickname or first names only and play data.

While no data transmission over the internet can be guaranteed to be 100% secure, we take measures appropriate to the nature of the data to ensure its security, such as encryption of data in transit and encryption of passwords at storage.

Kid In Story Apps

Within the "Edit Story" mode of the Kid In Story apps, a parent or educator may personalize stories by uploading photos and/or recording narration locally onto the device. None of the information you add or stories you create are collected by us. They remain solely on your device. In the "Edit Story" mode, a parent of educator can send and share a personalized story with uploaded photos and/or recorded voices of a child, or any other stories in the app, via email or Dropbox. We never receive these emails and do not collect any email addresses.

These apps contain a Community Library of stories that you may download. No personal information is collected when you download stories from the library. To publish your personalized story in the Community Library for the public to download, a parent may email the story to us at info@enuma.com along with a single sentence of a description of the story and the author's name to credit. We will reply to the email to confirm your parental consent to publish the story in the Community Library. Children under the age of 13 cannot submit stories to us for publication in the Community Library. You shall retain all ownership rights to and shall be solely responsible for your own Story and the consequences of submitting and publishing such Story. You may submit only Story that you are permitted to publish by the owner or by law.

From Our Websites: Enuma.com, TodoMath.com and KitkitSchool.com

To receive announcements about upcoming apps and other news from Enuma, you must not be a child under the age of 13. Parents and educators may join our free mailing list by submitting their names and emails through our website form. This information is used only for our internal purpose of communicating with you regarding upcoming apps and other news about us. No other personal information is collected. You can unsubscribe from the mailing list at any time.

You may also use our "contact" form on the website to email us with questions, comments and feedback. The contact form collects your name and email address and any other information you provide us in the "feedback" section. We use this information to communicate with you about your contact request.

Our email mailings may be provided to you through third party service providers, so we share your email address with them for the sole purpose of fulfilling email communications. The third party service providers are also bound by contract, terms of use and privacy policies to refrain from using this information for purposes other than providing services to us.

Automatic collection of information

When you visit our website, we send cookies to your browser, such as through Google Analytics, that uniquely identify your browser. We use such cookies to improve the quality of our service by collecting user preferences and usage information. We also use Google Analytics Demographics and Interest-based Reporting that collects information such as age, gender and interests. With this information we can better understand how parents and educators find out about us and may show Google AdWords advertisements on Google when people search based on our keywords. We do not merge the collected information with any personally identifiable information. Most browsers allow you to disable cookies or set your browser to alert you when cookies are being sent to your computer. Or you can also opt-out of Google Analytics here. We do not sell or share information collected with other parties. We may use Web beacons from time to time in our emails to learn which communications with parents and educators work.

SECURITY OF INFORMATION AND BREACH NOTIFICATION

We take care to safeguard the security of collected information. We use reasonable efforts to put in place appropriate physical, electronic, and administrative procedures to safeguard and help prevent unauthorized access, maintain data security, and properly use the information we collect. We encrypt data in transit and encrypt passwords at storage. We stay abreast of privacy laws and best practices and provide trainings to our team on the importance of privacy considerations from product design to service rollout. We limit access to the data to only our members who need it to perform their roles. If we become aware of unauthorized access of personally identifiable information, we will use reasonable efforts to contact our users through email address they have given us and/or notify through the app. For school accounts, we will contact the educator or school through the email addresses linked to their accounts.

How We Disclose Or Share Information With Others

We do not rent, sell or share any personally identifiable information collected on the website or through the mobile applications with other people unless we have your consent or under the following circumstances:

with third party service providers who work for us and need access to your information to do that work and use the information only for that work;

when we have good faith belief it is required to comply with laws or to respond to lawful requests and legal process;

when we have good faith belief it is necessary to protect the rights and property of Enuma, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;

in an emergency to protect the personal safety of Enuma, its customers, or any person

in connection with or during negotiation of any merger, sales of company assets, financing or acquisition of all or a portion of our business to another company.

when we share de-identified data with third parties to research ways to improve our services.

YOU CAN ASK PRIVACY QUESTIONS

You may ask to review the information we have collected and ask us to delete the information or to stop collecting any more information. To do so, please email us at support@enuma.com.

YOU CAN REVIEW UPDATES TO THIS PRIVACY POLICY

This privacy policy was last updated on January 5, 2018. Our privacy policy may change from time to time. If we make a material change to our policies, we will place a prominent notice on our website of apps.